after three sets of meetings, one in new york, july 2011, 1 in geneva in october and one in february after a short hiatus followed a december death of kim jong-il, we came to an understanding with north korea that would soon be called -- the federal 29th understanding, and understanding that we would pursue a path of confidence building, mutual confidence-building measures which would begin with the north holding its missile launches and nuclear activities and would be restricted by conference the measures on our own, and yet again, barely two weeks after this test in essence was administered, north korea announced it would proceed with a self-proclaimed satellite launch in clear violation, not only of united nations security counsel resolution banning such launches using ballistic missile technology, but clearly a violation of the understanding that we had. in retrospect, the federal

29th deal was a test just like the agreed framework and just like the september 19 statement. these three tests may have been different in terms of the speed with which they were failed, and the significance of this action so soon in the air of north korea's new leadership in terms of the federal 29th understanding was not particularly encouraging as prospects for authentic and credible negotiations. most importantly, for us federal 229th demonstrate north korea was not yet prepared to engage in negotiations with the sickness of purpose necessary to ensure that negotiations would result in concrete denuclearization process. so that was the 29th, 2012. and as you know, little seasons in seoul, washington and beijing were looming. and as north korea watched the

elections and political activities in those three capitals, it began for another series of actions which would commence in december with another launch, followed with a nuclear test the next year, 2013, followed by period of intense rhetoric and vitriol. so the question then, how were we respond? what should the future look like? what should it look like an this evidence in terms of north korea's intentions and growing capabilities? well first of all let me state, our north korea policy is focus on two primary goals. deterrence and denuclearization. i know many of you here from my colleagues and good friends, i'm sure he touched on a range of activities that we do within the context of the u.s.-rok alliance, our extended deterrence strategy, our joint

exercises, our planning under the variety of mechanisms that we have that feed our ministerial consultative meetings. as we explore long-term vision on how we security capabilities, develop the doctrines and train to counter the emerging threats and contingencies posed by north korea, the u.s. has together with its close allies with the republic of korea insured peace and stability on the korean peninsula for over 60 years, the alliance is strong, and it will continue to be strong. we have no doubt about that. on the denuclearization side, i thought i would share a few of our principles in terms of our diplomacy and our policy. you've heard it said before, but it's one of those statements that needs repeating, perhaps every month or so at least. the united states will not accept north korea as a nuclear

state, nor will we stand by while it seeks to develop a nuclear armed missile that can target the united states. it's worth making this unequivocally clear. it's also worth noting the international committee of greece with a series of united nations to get a council resolutions calling on the dprk to denuclearize. the result of three nuclear test now 2009, -- 2006, 2009 and 2013 is the international consensus, the undeniable consensus underneath for north korea to denuclearize. in pursuit of denuclearization, a number of principles guide our policy. first of all is the centrality of our allies, the centrality of our allies, traditional alliances, both with the republic of korea and japan. our dprk policy is founded upon clothes and transparent and continuous cooperation with our allies. glyn davies and i and our team

go out regularly to the region in close continuous coordinati coordination. pyongyang's efforts to drive a wedge between seoul and washington and washington and tokyo will not succeed because at the end of the day, i think you see this very clearly, evidenced in the north korea policies of our allies, we are not the only country that has learned the lessons of history that i just spoke to. second element of courses or close cooperation with beijing. united states and china agree on the fundamental importance of a denuclearize korean peninsula. we share common goals of peace and security on the korean peninsula but with open lines of medication and continually consult with china on how to advance these common goals. we see u.s.-china cooperation as critical to obtain meaningful

steps by north korea to meet its international obligations and negotiate complete and irreversible denuclearization. and in this regard china is a vital part of that the -- with the dprk with its unique ties with its unique ties with north korea. third principle is the principle of no rewards. united states will not reward bad behavior, its provocations, it's rhetoric, and his refusal to denuclearize will only lead to increased a dramatic and isolation to the security and prosperity north korea seeks will only come when pyongyang changes its course. it will not be rewarded. for bad behavior. fourth principle is i spoke about briefly earlier, but there should be no doubt that the united states will continue to take action in our defense and that of our allies. this includes maintaining a robust sanctions regime on pyongyang. this includes strengthening our alliances with seoul and tokyo,

to deter and counter the north korea threat that we and our allies face. fifth principle is to maintain an alternative path. as we said repeatedly, the united states will continue to encourage north korea to choose a better path that we remain committed to a diplomatic solution, a diplomatic solution that is based on authentic and credible associations leading to concrete denuclearization actions. the united states is prepared to help north korea changed its current course. the united states is prepared to sit down with north korea to negotiate an element the commitments that they have made but pyongyang must prove its services by taking meaningful steps to show that it has an intention to abide by its commitments, on its word, respect international law and engage in authentic negotiations. finally, and this may be considered our bottom line, we

will judge north korea by its actions and not by its words. this is more than a talking point but it's really in a nutshell the prudent lesson of the years of dealing with the dprk, which i spoke about earlier. so here's the challenge before us is clear. north korea in may 2013 announced the so-called pyongyang policy. the policy that seeks to pursue in tandem economic construction and the growth of its nuclear forces. one could argue convincingly i think that for the past two decades of the north's nuclear program, pyongyang has pursued a policy that sought economic gains while dodging denuclearization obligations. what we have with the declaration actually is party level strategic policy lines, clarity into pyongyang's overarching strategic goal.

but is passionate but as my cali, glyn davies, has noted a number of times, pyongyang does not positive in this regard scots i wrote a piece which i recommend highly to those of you have not seen it. forwarded deputy commander of dprk military region in an essay submitted -- forgive my pronunciation -- and our north korea denuclearization is more in accordance with chinese interest, himself noted, north korea second of develop and nuclear weapons is difficult to advanced composition nuclear weapons invites international condemnation, isolation and sanctions to be north korea unable to assess advanced technology, as well as aid for human, financial and physical resources. this makes opening up to the rest of the world difficult to achieve real results and leaves

into form lacks in, political and social economic environmen environments. general wang goes on to become developing nuclear weapons and delivery rockets use a lot of resources come against abortion large scale military which also use a large amount of resources. from an overall resource perspective, the sixes -- this reduces the strength of reform and progress. wang, therefore, conclude for chinese interest in north korea is interest, china must utilize political and economic and social governmental and non-governmental resources to convince north korea to abandon its nuclear weapons. this, of course, is the united states' policy as well. in this way and i say this in closing, pyongyang essential provides an opportunity, an opportunity to sharpen north korea's choices, to remind north korea that the security and prosperity it seeks are only possible through

denuclearization. a reminder that the policy decisions the regime has been making will only continue to lead to greater diplomatic and economic isolation and deprivation. to remind pyongyang that the dprk to pursue nicaraguans makes the country less secure and less prosperous, and to remember that the true victims of north korea's nuclear program of the north korean people, and to peace and prosperity they desire and deserve. thank you. [applause] >> now the floor will be open. >> thank you very much. it was a great historical overview which i think is critically important for all of us to understand, but with that, understanding the history, we are adding new point with the young leader with kim jong-un.

and i wonder if you could talk a little bit about your assessment of stability of his leadership, and if he is going through the transition period is still continuing and he hasn't stabilize his leadership, what are the chances for things going down the wrong road? and then, if and when he is in a stable position, do you assess that he will continue to follow the same path as you've outlined, which i really do like this transparent opec -- transparently opaque policy which i think it's a useful description. so if you talk about the leadership's ability and the way ahead, i would appreciate it. >> thank you. date, you know it's not very prudent to predict the future, but that said, what we see in terms of, if you look at and the reason i did this historical

overview is to show the continuities of these trends over time, and kind of understand that what we've seen in terms of the actions of the dprk over the past few years being entirely consistent with behavior that goes back, you know, two, two leaders, to kim's ago. in that regard, there's a degree to which the continuity provides a sufficient framework within which to make smart policy and that's why i use the transparently opaque formulation, to kind of get over this idea that somehow north korea is a country that nobody really understands and we don't know what they're going to do next, and, therefore, we are somehow handcuffed on a policy perspective. we have sufficient understanding of the dprk i think to make solid policy. the transition period is under way. it's an evolutionary process.

again, if you take a step back and look at the events of the past two years within the larger arc of where things were going when kim jong-un inherited this challenge, there's no inconsistencies or anomalies that would cause us to think that, you know, we are somehow not sufficiently aware of the direction the regime is headed with its goals and intentions. now, that said, this is why i spoke about the opportunities that pyongyang provides because the core of our policy has been one of sharpening choices for the dprk, to make clear that when the dprk is ready to commit to authentic and credible negotiations that have a serious possibility of living to concrete denuclearization steps, the other five parties which

include the united states are prepared to live up to their obligations under the september 19 statement, and fundamentally transform future is of able to the dprk when it makes the right choice. and also to be diligent and committed to sanctions and other actions that we need to take in our defense and that of our allies to make sure that north korea knows its program cannot continue to grow unabated, that there is a diplomatic and economic crisis to be paid for the pulsing choices it makes and, therefore, to understand the downside options and that sharpening choices strategy. ..

i think last year's tensions during the exercise period last spring, our reaction, the alliance reaction was very strong unlike it has been in the past and that surprised north korea. i say that because as you said, dave helby said the alliance is strong and provides a foundation for everything we do. i wanted to shift gears a little bit and ask about president park's's trust policy and how that fits with our policy supporting her, and i think the

importance of her policy, the ability of her policy to succeed also rests on the strength of the alliance but i wonder if you could talk about the relationship of our policy and president park's's policy. >> absolutely. this is an area in which our two countries have had very close and continuous cooperation even before the election when we first reached out to the political camps during the campaign. it was clear the trustpolitik was built on the same foundational principles that we had. flexibility, to talk, to explore, to probe, a strong commitment to denuclearization, clear linkage that negotiations that resulted in substantial progress in u.s.-dprk relations would be found on progress in denuclearization and this tracks very much with president pack's

articulation of trust polity and testing the north to allow humanitarian aid to go north but also to hold the no. accountable for its actions. what we have is an extremely natural partnership him u.s.-rok policy which i argue many people, i came on board three years ago just on the eve of the president's state visit, when they saw the improvement of relations under president li attributed to personality or commitment of president lee to u.s.-rok relationship and as strong as those were fundamentally the u.s.-rok alliance is based on shared interest, shared values and shared approach to a common thread that it is endorsing. even more so when you have president pack with a current trust policy. >> thank you for that.

larry? >> whenever -- i hear an administration official, this goes back into the george bush administration, not just the current administration -- talk about north korea or read statements in the newspapers coming from u.s. officials, there is a topic that hardly ever gets mentioned. and if it is mentioned it is mentioned only in passing. that is no. corey's proliferation activities especially its activities in the middle east. and i have seen and i have written about literally hundreds

of published reports quoting european intelligence sources, is really intelligence sources development of missiles and nuclear warheads. and the latest of these reports described in a south korean official was quoted in one of these comair and sending top missile experts to north korea in the second half of 2012, who assisted north korea in preparing for the successful long-range missile test of december of 2012. and reports that iran paid a

very handsome sum of money in order to send a very high level delegation of nuclear experts to the february of 2013 nuclear test but as i said, this is kind of the unwritten, not talk about problem that i think given all of the information that has come out in recent years that there is with north korea, this deep involvement between north korea and iran. we also have the wiki leaks documents describing how secretary rice instructed our ambassador in beijing to protest strongly to the chinese

government over aircraft from tehran and pyongyang, unloading people and apparently weapons in beijing's airport and transferring these between these aircraft from tehran and from pyongyang, a diplomatic effort which apparently bore no fruit. i am going to ask you, sydney seiler, if you can tell us anything about this north korean/iranian relationship and what is the substance of it? if you can say anything about that and there are intelligent sensitivities here but how much of a problem is this going to be? in any future diplomatic intercourse with north korea on the nuclear issue? >> those are excellent questions, difficult questions because they do it touch

directly on some of our more sensitive intelligence and sensitive diplomatic activities in our efforts to try to halt, prevent, rollback north korea's outward proliferation as well as not surprisingly the proliferation of technologies into north korea. this is a central purpose in the entire range of united nations security council resolution derived sanctions and other sanctions we put on north korea to not only impede the growth of the north korean nuclear program but imports of technology and the cash it earns from those sales but to prevent the outward movement of those technologies. in this regard let me just say a number of principles. proliferation is obviously a key top interest of this administration and any administration. we know the threat we face,

dangers we face in north korea's established record of willingness to engage in this type of activity is known to everybody in this room. it is but top priority issue. when we sit down with the north koreans and talk about february 29th to deal and sit-down in the six party talks whenever we engage with the north koreans this is a top priority. i would also say it is an area in which our international cooperation has grown markedly particularly since the 2009 nuclear tests and the 2012-2013 activities. we partner with a number of countries, china included, in a way that helps deal both with the flow of material, whether they are sea, air or land base as well as related finances. that is as far as i can take a public answer on this issue but it is certainly one that is of paramount concern to was as we

execute this issue. >> that was a fascinating and depressing history lesson you gave us on how many times north korea has violated its international obligations. you said we should judge north korea on its actions and the same should be applied to our negotiations with china because china continually uses the language you use about opposing nuclear is asian -- nuclearis nuclearisation and has participated in north korea's program and involve the original proliferation to pakistan which ended up in north korea. one could make the case china is not only a proliferators of wm d but a proliferation of proliferators. the network that emanates from

china has spread in the mideast and asia. i would respectfully question the assumption of the u.s. government policy, at least stated u.s. government policies that china shares our goal, our objective of denuclearization. their number one priority is not north korea's nuclear program but north korea's so-called stability in. rather than taking any kind of economic or other action that would put pressure on the north korean regime they would prefer letting it proceed with its nuclear and missile program as long as it remains as a buffer country between democratic south corey and china. if that is true it seems it requires more honesty in our public diplomacy. secretary kerry reiterated that year ago china made all these

commitments to increase the pressure on north korea. the only pressure it has increased his rhetorical. hardly any tangible efforts and yet the north korean regime would collapse tomorrow if china were to tighten any of its sanctions on fuel and energy and economic, diplomatic protection. it seems to me at some point this is the elephant in a room we don't want to discuss very often, that china has been a facilitator of the north korean threat and we should question what its motives are in doing so. >> i don't want to be a spokesman for the people's republic of china but let me speak to the elements of our cooperation. having the privilege of flying out to beijing once every couple of months or so and being very in depth, productive work done

this, six party talks, lead negotiator would outweigh the course of colleagues at the embassy and in china, china publicly the creation of the korean peninsula and the desire for peace and stability on the peninsula and northeast asia which both of those clearly overlap with the interest and desires of all the parties in the region in the united states, republic of corey as well. pierce has been a cooperative partner in the united nations, it has been enforcing security council resolutions and has put a lot of work into the six party talks process, september 19th joint statement of 2005 and all the diplomatic efforts that have taken place since then over the last nine years. this is a difficult issue.

it is an issue that many times when you sit down and try to brain storm over where is the solution to this? what are we failing to do? what are we failing to find? will ultimately need to step back and remember it is pyongyang that is refusing to e denuclearize or return to authentic and credible negotiations. you mentioned the prc does have a unique relationship and we work closely with the people's republic of china on this issue. this did not come up overnight nor will it be resolved overnight but it is an area we feel strongly committed to. our two leaders discussed this at the summit in sunny land in st. petersburg and the vice president when he visited and most recently secretary john

kerry. we continue to believe resolution depends upon sustained efforts to cooperate with china. [inaudible conversations] >> i have a question about self korea. in a recent days the attitudes of north korea to south korea is changing. north korea, i believe, yesterday, reunion talks of

separate families and scheduled -- in the same town. my question relates to do you think the changes of north korea's attitude is a strategic call or tactical? and the second do you feel any attitude change of north korea to the united states each >> we welcome the news that came in overnight of the willingness of pyongyang to go forward with the family reunions in spite of the fact that there is a small overlap with our annual legal exercises,

for sustained, real, substantive possibilities that north korea is beginning to turn the corner in this more bellicose rhetoric and actions and hopefully then they will soon see the value of returning to authentic, credible negotiations. >> does this follow on this question? most koreans shoulder the decision, nuclear is asian -- united states.

and then the meeting for the immediate area of the nuclear problem. you deliberate even more of that. >> in terms of the signals that the dprk may or may not have sent in terms of the willingness to engage in denuclearization negotiations we have not seen anything that clearly signals their preparedness at this point. we know they made a national defense commission statement in the middle of last summer. the more recent proposal, none of this do we see any indication that north korea is interested in denuclearization talks at this time. we remain open to that. the united states is open to authentic and credible dialogue and we hope that the positive

signal pyongyang may be sending to move forward with family reunions represents the type of shift in their attitude and behavior we have been waiting for. >> peter kong with the freedom alliance. i am a chronic pessimist about north korea nuclear issue. i had a great time crossing with north korea analyst and myself some time ago. so glad to be with him again.

you describe many things like u.s./south korea alliance and we are not going to get into any talks for the sake of talks and so on but looks like when you say we are not going to talk unless you are ready to talk seriously, we keep wasting our time. the current getting together, in korea, getting -- i keep losing some words, getting -- getting north and south korea, that is good news but that doesn't give me any hope about the nuclear

issue no matter what comes up. we keep losing time, looks like we are waiting on north korea to accomplish to reach alaska and beyond and i don't see anything else going at this point so could you kind of help me with my concerns? >> i tried to frame my presentation although i didn't give extreme good amount of attention to the first part of it but to this idea of deterrence and corean-american efforts -- denuclearization efforts. these are the steps we need to take as north korea makes as a strategic goal the pursuit of a nuclear force developing increased missile capabilities and openly threatens us with

them that we take due diligence that dave helby discussed, the areas of activity we are taking in terms of missile defense, extended deterrence, the entirety of our discussion with rok on the alliance and trilateral cooperation in the region with japan is crucial on this. japan is a partner in missile defense, crucial on this. a variety in ways in which we in essence denied north korea the value of its nuclear deterrent by making it irrelevant in light of our ability to counter it. taking it very seriously, not irrelevant to the way we can ignore but sufficiently postured to deter and defend this emerging capability. the second part of the discussion which developed a bit

more, with some degree of understanding of the history of where we have been, talks in and of themselves have no inherent value particularly in slowing the program without the types of actions like sanctions, countersproliferation activities and continued pressure necessary to ensure that north korea pays price for its program. simply talking for the sake of talks doesn't necessarily get you, doesn't necessarily slow the program. people are inclined to look at the status of the dialogue and say in the absence of dialogue the program is growing. and make a false causal relationship there that i find it hard to accept. we want to have dialogue, concrete denuclearization steps.

we had a dialogue that with the first and second phase action statements in 2007 led to the disabled and the modified megawatt reactor and the fuel facility and reprocessing facility led to the collapse of the cooling tower. we were on a path toward a reduced quantitative, in terms of plutonium inventory half and yet north korea broke out of it and now has taken steps to restart its plutonium program and the enrichment program continues to go on. i appreciate the frustration. that is why we see a sense of urgency. that is why we continue with a relatively robust pace of denuclearization diplomacy particularly with our prc allies and with russia as well.

>> you have something on your mind? come to the microphone please. >> thank you very much for your excellent presentation. i was glad to learn that you studied very much the history of the conflict and are well aware of the fact the current situation is a result of many loose ends. as you put it, our policy now is sharpening dprk's choices but we already know that they will pick nuclear over economic improvement because we have seen that they are willing to let millions die of starvation

before letting up on their regime. i want to ask whether this avenue of pressure could be considered. it would have to come from the ngo community as opposed to a state. to press for the indictment of kim jong un by the international criminal court based on the jurisdiction that the republic of korea encompasses the full korean peninsula as it states in its constitution and of course that is one of the examples of louis ends from the unresolved conflict. i can't imagine any other non

kinetic full of pressure to have greater effect on kim jong un than the prospect of criminal prosecution. based on the notion that dprk shouldn't even exist. what about bringing something new in to pressure to shake up the stakes more. what is he going to do in response to that. there's not much he can do but he will learn very quickly that he is not getting anywhere with the game he has been playing and his predecessors have been playing. >> interesting question. sometimes in the course of the

focus of the denuclearization issue and this is somewhat because we do have two -- we have a special envoy dedicated to the cumin rights issue, a special representative with glenn davies who looks at the larger, broader north korean policy. at times people forget as we talk about uranium enrichment and plutonium and warheads and missiles and proliferation of the plight of the people of north korea. first of all that is absolutely not the case in the white house as we look at this issue holistically. we continue to be concerned about the human rights issue at dprk. we continue to want to work to bring the north korean people the same peace and prosperity and freedom and respect for human dignity their brothers and sisters in the south enjoy.

the trends of history are inevitable to the president spoke of this at the university of foreign studies during his state visit. the vice president touched on this in his own speech during his december visit. support in particular for president pack's unification strategy which themselves are driven by a desire, the north korean people would one day be free of the situation they are in right now. we will continue to create an environment, we believe we have put on the table in our diplomatic approach an alternative path for the leadership of pyongyang to choose. i don't want to prejudge the leadership.

it is relatively new leadership. there are has before it and there are conditions we can create to lead them down that proper path. i think that is what we continue to need to do. i encourage in particular ngos to have an interest in the human rights issue to keep that front and center. i believe as in the case we found with authoritarian regimes in the past, voices from the outside matter. they are encouraging to the people. perhaps that is more important than whether they cause the leader to change his attitude when he or she wakes up in the morning. this is the right thing to do. we will continue to put the focus that we have on this human-rights issue continuing going forward. >> don? please.

>> i am new in this feels. matter of faculty and study history. the question to sydney seiler, since you review chiefly north korea. >> no ancient history. >> do you see anything when second kim took power, what i meant, kim sr. thought there was no way we could fight any more. that is good in economic development. his son doesn't like it. same thing happened over and over again and realized it doesn't work, we got to do

something. now young turk, same track. question to you, look at that issue. second, in future policy direction you see the enemy, you can beat him. cannot involve internal politics too much. the republic of korea constitution peninsula, and they have power, control. without any legal obligation. that set up policy, the whole korean peninsula, america oversee stayed behind, let the

federal government be the reaction. the chinese government also has taken more action. we cannot do anything. take the prospect of correction of policy. >> this may bring me close to the borderline i said i wouldn't cross moving from policymakers to analyst. an interesting question. i think the challenge with the understanding north korea's motivations in 1994 as to why we moved into a period just up to the death of kim il-sung, a period where north korea put its nuclear program under wraps if it were, froze its plutonium production, processing campaign

of 2003 and engage in a diplomatic effort to improve relations with the united states. there is a variety of opinions on that, who believed it was a sincere effort to try to explore a post cold war world in which fundamentally better u.s.-dprk relations, some people say north korea simply felt its existent nuclear deterrent as it were was insufficient cause to protect it from the forces of history that appeared to be unfolding and fought diplomatic report -- rapprochement was the best way to guard against that. is very speculative but the challenge that we face is the regime's inherent perceptions of the world in which it lives, it's worldview as i call it.

we have tried many things in the six party talks process in terms of discussions on security assurances. the whole 6 party talks process provides a very hospitable diplomatic environment. of the dprk were concerned about hostile forces from without threatening the regime's existence, it is in a diplomatic environment, six party talks that should be very reassuring that the security it has, it desires, can certainly be strengthened by pursuing the path of denuclearization. it is inherently the regime lacks confidence in that. we need to continue to try our efforts to remind the the regime that there is an alternative path, that the true security it

seeks is not nuclear-weapons and that is going to be a process that if there is a transformation in north korea under the new leadership that by our sharpening choice's approach we can continue to send that message and provide that alternative path and continue to demonstrate our willingness. president obama said, to reach out his hand to those who will unclench their fists. to your second question, i think the transformation potential that lies in rok and its policy toward north korea is eminently understood by president hack and has been at the heart of the trust process, trustpolitik policy, and also the driver for more recent emphasis on

unification, preparing the korean people to move down a path that all 70 million korean people have as their aspiration. i think that there has been some legitimate questions that you embrace of race. i don't think it is worth exploring at this time considering the sensitivities of some of the details. what is clear is as pyongyang looks at its surrounding environment agency and number of countries that are willing, ready to help it pursue a different path when it makes strategic choices that we are calling. >> thank you. >> back here. >> please. >> thank you so much for your talk.

two part question actually. the way you outlined the current approach in policy regardless whether people agree with it or not, the rationale, the logic, we should try any approach possible to try to solve this problem. the question of clarification, meanwhile, the north is engaged in developing nuclear missile capabilities. does that mean the current approach and policies that we believe that time is on our side, that we can wait however long it takes, years or months or decades for north korea to show credible steps, credible elections? the first question is time on our side? is that the assessment that formulated into this policy calculation? and the second question is, the rok, a pillar of their current

policy is one principle is to try to induce the north to change its behavior actions or change in general. and i imagine that this view or this principle is pretty much shared with the other five parties based on looking at different coordinations happening among the five parties. other than the sanctions tools, how else can we try to induce behavioral or action change from the north without having direct contact with them, however way you want to define contact? >> two great questions. in the pursuit of the policy principles that i discussed, i would urge people not to characterize or assume that we see time as on our side.

we see this issue as necessitating a sense of urgency. we have articulated that with our fellow six party talk partners. urgency not just to return to talks for the sake of talks that have no credible likelihood of leading to concrete denuclearization factions but a sense of urgency in terms of really making the choices clear to north korea. at this point in particular, following the events, the internal events in north korea commack as the new leadership maps out its future path that we are consistent and principled in the choices that we provide, it is a principled approach, sustained approach and one that isn't one of strategic patience. we never used the term or said time is on our side. justof strategic patience. we never used the term or said time is on our side. just the opposite is true.

with the united nations security council resolutions we can begin to bring north korea to the conclusion that it has a better future through denuclearization and that is the path that we continue to believe is best not to reinforce past bad behavior but to induce the type of behavioral change you mentioned as the policy goal of president hack and the republic of korea. i do believe beyond sanctions and the specific actions that we can put in place, north korea's stated policy that it is going to continue to pursue nuclear weapons in spite of its international obligations, in spite of the international community consensus that the north should denuclearization it will continue down this nuclear path while pursuing economic

construction, recovering its economy. we are at a crucial time when the international community needs to be decisive and resolute in sending a strong message to pyongyang, this simply is not possible. that can range from specific actions and measures taken to things not done. tourists who have seen, if you do travel advisory dprk and look at the number of countries that strengthen their travel advisories in light of events in the cases that unfolded with kenneth bay -- kenneth bae and others, north korea is not a safe place to travel to. and economic development strategy that is based upon

tourism brings into question yongbyon, enticing foreign investment as north korean moves through its provocation cycles, its missile launches, nuclear test. not a conducive environment one would think would be needed in order to bring international investment. this type of consensus is build internationally because it need not be in your face denuclearization or else threat but when north korea here's the unanimous voice which it is hearing, the leadership should be more inclined toward the type of behavior and the type of decisions that our policies are designed to elicit.

>> ladies and gentlemen, thank you very much. mets here it, a round of applause. [applause] >> small liberty bell from philadelphia. >> thank you very much. ..

we ask that you come to the microphone, identify yourself, present your question, and proceed from there. our topic this morning is implementing the food safety modernization act. since the legislation was signed into law in 2010, the food drug administration has been addressing the process of issuing final rules. rules have been proposed in seven areas with comments closed. one maybe we -- reissue. fda continues to work to the thousands of comments received. in fact, fda declined our invitation to participate in this forum, citing their heavy workload. the food safety modernization act shifts the focus of federal regulators to prevention of foodborne illnesses rather than simply responding to contamination. new regulations are proposed at

the farm level. for some, food processing facilities and for food importers. we have a distinguished panel with us this morning, of those being affected by this new rule, or this new law come to discuss the impacts of this legislation. opening our session this morning is christopher waldrop, director of the food policy institute at the consumer federation of america. his bio is in your hand out and available on the audio cast. chris is going to provide some background on the act as well as consumer perspectives. chris? >> thanks, charlie, thanks for the farmed foundation for the invitation. again my name is chris waldrop codirector of food policy. cfa is a nonprofit consumer advocacy or decision founded in 1968 to advance the consumer

interest of research, education and advocacy and we are made up of about 300 member organizations national as a small state and local organizations all across the country. since fd is not here today i will do a little background on fsma and talk about the context of how fsma came into being because i think that's important as we're thinking about implementation. cpcs at 49 americans are second every year from foodborne illness, 3000 won a 20,000 are hospitalized. the economic costs society of foodborne els elves have been estimated to be $77 billion per year in terms of lost wages, medical costs, time off of work and that sort of thing. in the years leading up to fsma consumer saw just a sort of steady stream of large nationwide foodborne illness outbreaks linked to common everyday foods that most consumers have in the house and consume on a regular basis, things like spinach, peanut butter, eggs, peppers, a number

of other foods where consumers were seeing these outbreaks repeatedly and over and over again. in addition consumers were expressing concern about the safety of imported foods and the inability of fda to police the imports coming into this country. fda can only expect about one to 2% of all imports into the u.s. in addition we were seeing economic cost of the food industry as well. so the 2006 e. coli outbreak that was linked to spinach cost the leafy green entry $350 million, and kellogg's was broke and the pca peanut butter recall that was nationwide and caused kellogg's itself $75 million as a result of that recall. so there were some real economic costs to producers and processors of cracks in a food safety system and a lead to declines consumer confidence both in terms of government as well as industry. and incidentally just last month a harris poll came out looking at consumer concerns and issues around food safety, and they

found 73% of consumers want more oversight of the federal government around food safety issue. so clearly consumers expect the government to play a role in food safety and fsma was sort of the result of that and that 2006-2010 area. there were strong support for fsma by both consumer groups and the food industry. there were strong bipartisan support for the bill. congress passed the bill with bipartisan support in 2010 and president obama then signed in early 2011. now, the sort of key elements of fsma as charlie said, it fundamentally shifts fda approach from reaction to prevention because a huge shift and most of the components in fsma were guided and focused around that. there's a new inspection mandate for fda that increases inspection frequency for both domestic and imported facilities. a requirement that food plants develop and implement preventive process controls to reduce contamination in food plants,

requirement for the first time ever that standards for safe production of fresh fruits and vegetables on the farm. required fda to develop systems to address important safety and a better safety of imported food and there's such a different element, the voluntary qualified importer program and third party certification all kind of work together as well as working with foreign governments to develop, better ensure the import of food to push back towards the country that are exporting to the u.s. it requires enhanced traceability high risk food products come enhanced surveillance of foodborne illness outbreaks and better cooperation between fda and other government agencies including state and local agencies, provides fda with a 30 to set standards to reduce pathogen and then provides a day with mandatory recall authority. those are sort of the fundamental and key elements of fsma. in addition to was that test -- the tester amendment which

provided exemptions for certain small businesses that market the majority of their food to it directly to consumers or to certain restaurant and retail companies within a particular radius and that exempted these forms are these facilities from safety regulations. it provides, requires facilities to adopt modified preventive controls or to demonstrate document compliance with state and local, and for the farmed it requires the farms to label or have some sort of signage, contact information for the farm when they are selling the products. now as charlie mentioned, all seven of the major proposals have been released. you can see them here. the first four, the public comment period has close although fda is going to reopen the public comment period for certain key provisions of the preventive controls and approaches the safety rules that were particularly controversial or fda want to sort of take a

second attempt at them. and get additional comments and kind of see what they can do. the last three are still open to build the additional provisions like traceability, performance standards that will come later. fda also has to define sort of how they're going to fight high risk food for certain at this provision. they released the methodology on that and will begin develop in the list at some point in the future. the other thing to know about implementation is fda is now under a court order to publish all the final rules by june 2015, so the clock is ticking on this and fda is needing to work very hard to make sure they're reading all the comments, incorporating all the changes, repurposing the key provisions and finalizing these rules by 2015. so just in my remaining few minutes i want to highlight a few consumer concerns, consumer issues would like to see in terms of changes to these rules. consumers, groups of jelly want to make sure that fda is

something fsma in a timely way and consistent with the law and make sure that adequate protections for consumers but we generally have supported the rules that have come out so far we've commented on by the are some key areas we would like to see change. in terms of preventive control, fda did not record the company's to implement either environmental or finished product testing other products. that was not a requirement in the rule, neither did it get require food manufacturers to develop and maintain a supply of verification program. both of these things are best practices in food industry today. they are, practices and we think fda needs to restore those elements into a final rule so that it is a requirement for testing and a requirement for supplier for vacation program. on the produce side, cfa supported fda's approach to regulate risky practices as opposed to risky products. so the practices that are going into the product in terms of

worker hygiene, soil and menace, water, that sort of thing, but fda did carve out an exemption for certain products that they defined is rarely consumed raw. and we don't think that that is an appropriate exception. we think a lot of the products on the list actual our consumed raw by consumers, and that the cross-contamination issue that can occur in the kitchen if some of those products, with pathogen. we would like to see that exemption closed. we do support some sort of numerical standard for water testing to be able to have some determination that the water that's being used has met safety standards to fda is going to we propose that so we're looking for commenting and see what that is proposal is similar for two that. we do think fda should require some sort of environmental testing in packing shed. this was particularly highlighted in the wisteria outbreak in 2011th link to cantaloupes weather was with us to contamination in that packing shed. had he been testing for that they may been able to find and

avoid an outbreak of those deaths and illnesses. fda get require importers to develop and verify that their suppliers are producing food safety. the agency gave importers to options. one is an annual on-site audit of their suppliers any other sort of a range of options, a menu of options. we believe in annual on-site audit is essential so that the importer has some assurance on an annual basis that their supplier is producing safe food, providing them with safe food and not just doing a paperwork check so that they are on seconds he was going on and maintain a relationship with their suppliers. and finally third party certification program, this is a new area for fda, sort of uncharted territory for the agency although they tried to align what to do with some of things that are of enough -- that are out there now. third party certification programs has been hurt by things like jensen forms npca and

wright county as where third party auditors went into these farms are these facilities, gave them very high marks and then weeks or months later there was a huge nationwide outbreak that sickened hundreds of consumers. so conference in the systems isn't high. so for fda to build to incorporate those they need to ensure that the adequate transparency which includes things like providing the public with robust information about the entities involved, self-assessment reports, audit reports, unannounced audits and be an important part of that element as well and then adequate oversight of program, making sure fda has a good sense of what's going on with the different entities that are performing these certifications so they can oversee that program and not just set it up, let it run and never pay attention to it again. those are just a few o of the areas where cfa has raised concerns and wants to see some changes. i'm sure we'll get into more detail in the commentary to look forward to that, and thank you

very much for the time it. >> thank you, chris. [applause] >> next we welcome to the podium richard gilmore, ceo of gci trade in incorporated and founder of the global food safety forum which develop public-private partnership risk minimization. food safety strategies in asian markets in a global food chain. rick is going discuss the legislation issues related to food importers. >> good morning, everyone. so, fsma is really, we regard fsma in the international perspective as a catalyst for change, both in the u.s. context but also globally. and our focus in global food

safety forum has been the asian markets with prime attention in china where we have an office and are active and so probably what i have to say is certainly to a large extent influenced by the work we're doing in global food forum. the current problems that exist in the global supply chain, which this and is designed at least, it's objective, to address, art, for example, regulatory gaps for the mitigation of risk, protection, protecting consumer health and racing consumer confidence as noted in the previous speaker. we have as another problem, inability to handle emergency contamination issues consistently and reliably. there's an absence of uniform

treatment domestic and international product. i will be coming back to that and i'm sure that will be perhaps a source of interest for you since there's been a lot of discussion around that set of issues. frequently, there are less reliable technologies from foreign suppliers for tracing and certification from the point of origin in foreign supplier markets, or if you take just in an anecdotal way, when product is transported by truck and documentation is required for refrigeration, if you've ever been to some of these, some of these locations where we source product, the ability to do that and conform to that documentation can be very difficult, and fsma nonetheless rightly requires. concerns regarding independent verifiable certification on

site. this is the third party audits. if it was difficult in a domestic context, it's even more difficult in the international context. the acceptance of that third party certification and the problems that surround that. there is potential for fraud and gaming the system, and i'm sure you've all read some of the most flagrant abuses in that regard. and the absence of harmonized standards with international acceptance of those harmonized standards is a need for private, public platforms. there's hosts for information sharing and collaboration. i want to stress that. that's our niche, but that's i think welcomed in the fsma strategy. the lack of equivalency in regularly systems worldwide.

these disparities notwithstanding this month and the u.s.a., et cetera, are considerable. here are the international provisions that i would highlight, the sanitary -- within fsma, that certainly foreign suppliers are focusing on and gearing up to try to address. our moderator introduced me in saying that i would be addressing it from the importer site. i do want to note that fsma is also, helps to identify the u.s. brand for food safety and food quality as an exporter. so sanitary transportation, focused mitigation strategies to protect food against intentional

alteration, accreditation of third party auditors, foreign supplier verification programs, preventive controls for food and animals, and the private sector and preventive controls for human food. here's a bit of a status report of implementation, previous speaker certainly covered the first issue, namely the deadline of june 2015. and that's going with one respect to accommodate all the concerns of growth and industry is an important timeframe, but at the same time having passed the fsma and introduced some of those regulations and announced them in draft form create a level of uncertainty for producers and manufacturers, not only in the united states but

globally. fda's budgetary constraints which fda in testimony just last week on the hill didn't hesitate to say how they need 400-600 million more to get their inspections up to target and so that remains an important issue. continuing and potentially growing discord in the roar manufacturing a national supplier communities. there isn't a manifestly clear single voice when it comes to the endorsement of fsma, the application, and its acceptance locally. what's the international footprint, we call it, for, that is impacted by fsma? this is just a little summary display that tries to show the

relationships that all or involve inherently in the implementation of fsma. so in the center, because this is not, i mean, most importantly of course it's human element and consumer confidence, that at the same time this is an industry and is a very important one to our economy. so the commercial stakes are huge. and that's why they're in the center in this little organizational chart. trade and national security interest, we don't always touch on those, but they are there. passage in viruses and fraud are disrupted to international trade. security concerns are very much there related to undetected viruses. there's the potential for international misunderstanding and weakening the fabric of international organizations and

standards around codex and, of course, iso 9000. i forgot we got a very fancier. so my apologies. partially because i'm colorblind because i can't see red. the role of the private public platforms that's a global food safety forum. it is come one, maybe for some foremost is information exchange, too, its joint venture investment in new food safety technologies from the operating system, tracing, certification, all of that is addressed within forums such as ours. and collaboration, business-to-business and with government regulators to ensure uniform compliance with international standards and reduced incentives for fraud.

the achievements of global food safety forum, we did receive a usda grant and we received chinese government in kind support. we've had several conferences worldwide. we did corporate site visits. we have partners like the center food safety, defense what you probably know of in minnesota, it's a consortium of 40 universities. we work closely with food and drug law institute. so these partnerships would like to integrate into these hands-on activities that we do. chinese delegations visit to the united states, this year we intend to launch online courses on food safety for chinese companies and government regulators. and most certainly in that context there will be fsma compliance courses as well.

and launching food safety comment and our big project which may not be completed this year but we been working on for about six months is launching a food safety liability insurance product for recall contamination in china trade, which does not currently, and surprisingly, exists even to the satisfaction of international buyers, as well as suppliers. here's what we think we can do for u.s. products. again, very much in the context and in synchronization with the implementation of fsma. we did as noted received a usda grant and that is to promote the brand of u.s. food safety and quality in our exports. collaboration as noted with businesses, harmonization of standards, the ability for self revelation, something that is

again presumed within fsma, because fsma and fda has to work closely with industry for successful implementation and compliance. a forum for dialogue and policy formulation, both industry and government, and a platform for regulatory agencies to broaden and widen their outreach and achieve greater and more uniform compliance. i look forward to questions. thank you very much. >> let's hold our applause. we did chris, he gives a little extra for today but since we have to allow the listening audience to participate it doesn't seem fair so we will appoint everybody when we finished today. thanks, rick. next we'll hear from dennis nuxoll, representing farm

families growing fresh produce in arizona and california. the members of western gross provide half of the nation's fruits and vegetables. including one-third of the fresh organic produce. dennis. >> thank you very much, charlie. good morning, everybody. good morning to you out on the internet. again my name is dennis nuxoll, i'm the vice president for federal affairs for western growers, as charlie mentioned, our growers, we are a trade association of growers who grow fruits, vegetables, tree nuts. we were founded roughly 90 years ago. in california and arizona. most of our members are headquartered there but we grow in roughly 30 states and some 20 odd foreign countries. as charlie mentioned when you aggregate all of our volume together, our growers collectively represent 50%, roughly 50% of the fruits and vegetables in the united states, and roughly 99% of the tree nuts

grown in the united states and about a third of all the organic production in the united states. and i should say we are all sizes, we're small, medium and large operations of all sizes. i've been asked to talk about the control rules on the product safety rules, pursuant to fsma, and i'm going to limit myself because of time to the produce rule, what i look for to talking of preventive control rules as well. i wanted to start about talking some passionate about some overarching thoughts and this is going to sound like a lot of criticism, and i think all of us have talked about ways that the fda can improve the rule. so let me start by saying we think the fda did a really good job in executing the food safety modernization act. i think chris mentioned that they were required to issue seven very detailed, very specific rules over what are

really very different topics. we think that they did a very good job doing that. think about the produce rule. in the produce rule, fda has to start thinking about, for example, agricultural water, how agricultural water can be a pathogen, a vector of pathogen and contamination for literally every single crop grown in the united states, across every growing region in the united states. it's a significant challenge, one that we think that they did a very good job in tackling. i will, however, say we're very appreciative that this year we are going to have an opportunity and fda is looking again at at least a couple of the critical element of the produce rule, a couple of the critical elements around water, soil, a couple items similarly with the preventive control. so we are very appreciative of that opportunity and it's in that spirit that i want to talk about some of our thoughts about

specific suggestions. to start off with, western growers believes that every operation regardless of scale should have some type of food safety plant. there is a very complete body of literature that talk about food safety outbreaks at all scales, whatever the scale of operation. and to we think that every operation showed and could have a food safety plant. in fact, we know that this is possible because over the last three or four years usda has had outreach programs to engage producers of all scale on food safety. so you know that is for is one of the fundamental premises when we talk about food safety. we think that a food safety plant is appropriate for every farming operation regardless of scale and size. secondly, we think about the food safety modernization act and the resulting rule, one of

the objectives we believe that is important to consider is that the rule should reduce the need for multiple redundant audits. and, frankly, it's one of the things that isn't talked a lot about, but for growers who have a standard set by albertsons and the standard set by safely in the standards set by whole foods and a standard set by wal-mart come you might have a grower green 100 acres for giveaways because those standards for food safety are not uniform. as i think chris mentioned certainly consumers are very focused on food safety. that is reflected not only in the legislation that was passed by the clearly in food safety efforts that individual retailers are now pursuing and creating their own standards or looking for standards that they can adopt in food safety. so that's one of the things that we believed needs to be perhaps thought about a little bit more is how can we have this federal

standard eliminate and reduce multiple redundant audits and multiple and redundant systems. that's over growers are already safe. let's not add another audit and another system on top of some of the commercial standards that are already in place. finally, all operation should be covered by only one rule rather than fragmented rules that preventive control and produce rule currently have. i'll talk about that in the next slide. in the produce rule, a couple of, a couple of thoughts. again, and i just talked about this but we believe every operation should have a written food safety plan. we think that the way fda implemented the tester amendment, i think chris mentioned the tester amendment, an amendment that attempted to exempt certain small growers. we think that the fda as they wrote the produce rule has

actually exempted a larger universe of growers then the tester amendment originally envisioned. and again since we believe that every farm operation, regardless of scale, can create, and should have a food safety plant of some type, we think that that's over encompassing definition from fda should be amended. speaking of definition, we think that definition should be clear, or size, and standalone. i suppose i could talk about five or six or seven dozen, you know, very technical definitions here. i'm not sure, charlie, the audience would appreciate the. suffice it to say, we think that definition should be clear and concise and standalone. ownership of the product should not determine the rule to which the product is subject. what does that mean? well, in the preventive control and the produce rule, one of the elements that fda looks at any coming which rule do you fall under, is who owns the product.

so we have lots of growers, this is a fairly common circumstance, i met 100 acres of let's say cabbage and 50 of those acres when i go out and harvest, i harvest for my own label, my own brand, and that enters the system of commerce under my name, or my logo and brand. but the other 50 acres i may be contracting with some other entity. so maybe i'm contracting with one of the grocery chains that i just talked about, albertsons or wal-mart or whole foods and maybe it's their brand, their logo on the cabbage your way the fda has these rules interacting, i may now be subject to two different rules, even though it's the same operation, the same process, the same product. we think that there needs to be some rationalization of their, and specifically what we're interested in, in that regard is looking at the risk of the

product and the risk of the activity, and what is the activity, rather than worrying about what the ownership structure is for that particular, in this case, harvest, and that really should dictate how the rules, what compound operation is subject to a rule. finally, apply the rules uniform a to both domestic and foreign operations. rick, we just heard rick talk about that so i will leave that aside. some of the general requiremen requirements, here i think one of the medical things that we would like to see revised if possible in the rule is, in both subpar to be in the will talk about this later, subpart p, and that is creating greater flexibility to create alternatives and variances, conception they are very similar. the idea is if fda sets out

standards and rules to accomplish a certain level of food safety health protection, there should be some mechanism to create alternatives for the. there may be other ways to accomplish the same objective. flexibility, right? conceptually, fda tested it on a. they have actually created not one but two mechanisms to create alternatives. there's a mechanism subpart d., subpart p, and so we applaud that but one of things that we would like them to refine and improve is with respect to the alternative mechanism in subpart p regattas limi limited on wated soil components of the rule. there are several components to the produce rule. we think that if you're able to demonstrate an alternative that a conscious the public health objective, you ought to be able

to demonstrate that with respect to all components of the rule, not just water and soil. secondly, the rule talks about establishing the same level, quote the same level of public protection. that seems quite reasonable, but when you actually read the rule there isn't a clear criteria and method and process by which you can accomplish that and show that. and in that regard, you know, we would consider, and we've suggested the fda that having an extra review process in order to approve alternates, allow those was approved to be widely available to other growers, makes a lot of sense. and then we also talked, the rule talks about meet the same microbiological standards. and again, i think when we talk about trading alternatives, conceptually the idea of creating flexibility is useful,

and certainly as a member of congress, charlie, i know when you wrote rules and the laws you always thought about alternatives and things being flexible so we applaud that. but we need to make sure that fda creates a real method and process and system that produces an action create alternatives, published in and have been working on the ground. and so that sort of the idea on that concept. subpart c. talk about personal and qualifications and training. for us, the critical component here is that the way the rule currently is written, and this gets very technical but for those of us in washington and the beltway, the rule talks about the need to training and education and experience in order to be certified as an individual. when you make all three of those things requirements, i'm not sure how a new employee would ever be certified, and ever be

allowed to participate in this system. and the one of the things we've argued, this is i guess it's a minor fix, but the idea is that you should have the ability for individuals to demonstrate qualification separately, trading or education or expand rather than the and clauses. and that's a very technical but for those of you, especially for those of you out in the countryside, it seems technical. for anyone in the room you understand the sort of regulatory speak and how that could be a problem. subpart d., agricultural water. this is a part of the rule -- e. has been very controversial. chris, you mentioned it in your introduction. i would say from western growers perspective, we do not support road testing the road testing programs. instead of what we think about

is that the rule has to recognize that one size does not fit all, and water use in different agricultural, for different crops and different settings has different risks. and so that is part of the rule that we would like to see altered. and let me to you an example. testing, testing frequency, the testing criteria for lettuce, let's say, which is a crop that is intensely watered, water touches about crop all the time. the testing regime for lettuce ought to be significantly different than a testing regime for an orchard crop where water is used clear to, you irrigate the crop, you are irrigating the tree come you are occasionally sprang into the tree for temperature control. but the testing regime and the amount of water that touches the crop, the edible portion of the

plant in an orchard context versus a lettuce context are radically different. and so from our perspective, we think that programs the layout every single crop test, every seven days as i think the rule states, a certain testing regime and having apply to physical crop in their single growing region without variants, that doesn't seem logical to him. and what we want fda to focus on is the proper focus on the focus that chris talked about early on and the intent of this which is to focus on the wrist, right? how do we minimize risk? we sorely are not going to eliminate risk in the system figures was going to be some risk by the idea of this is to make food safer. we acknowledged that, and the idea really than is how do you have water testing calibrator of programming for the risk associated with that crop, that

cropping system, that region, that doing space? so that's on agricultural water, conceptually where we would like fda to go. on soil amendments, and you know, there is a large body of literature that talks about raw manure being a significant and animal feces being a significant factor of pathogen contamination. from our perspective we want to discourage all, i repeat, all overall and untreated manure on crops. we are also similarly as a consequence concerned about some of the yard trimming standards that are in the rule. but from our perspective, you know, there is a significant, i think there's a significant debate around how to treat many

were, how to heat treat it, how to compost it up properly to remove the risk factors of pathogen contamination that manure can have. that's a significant body of size. there is a lot of literature on the subject. i think that he is doing the right thing by re-examining that space, but fundamentally, making sure that we're all -- raw untreated manure is not in contact with product is absolutely appropriate, absolutely correct, and looking at the side sites to make sure t the science is right on soil amendments and making sure that we have the right standards set for composting, for example, for organic product. i think that's another place were fda has gone back, is in the process of reevaluating. is another example of fda really handling this appropriate, which is going back, taking sure the site is right and what is a critical area.

one of the things on soil amendment. imbecile a minute rule there is requirement to test for, i think it's wisteria. we're not entirely sure there is a valid way currently to do that. so it's a little, we are a little unclear what fda would be mandating testing for substance where no test yet actually exist, right? so maybe that's an aspirational goal, but that may be something fda wants to clarify. animals, and we have talked a little bit about animals and action works nice with this concept of manure in feces. western growers was involved in the wake of the spinach outbreak that chris mentioned roughly 10 years ago. we were involved, heavily involved in writing was called the leafy green marketing agreement. it is a cloud of agreement between the industry, states and federal food safety officials.

and it's an agreement that lays out, sets out comprehensive, very detailed food safety standards. and from that experience we have seen differences in how animals are treated in the food safety context. and the one thing that i'm will leave you with is the need, i think for fda, they need to recognize different levels of risk. initially on animals, the idea was to prevent animals from ever entering a field. there were scientists that would come out to her feels 10 years ago and they would would be aghast that birds were flying above the field. god forbid that a bird actually and in your field and there might be feces on your field. it's not a sterile environment, right? and i think over time people have got that, but certainly the initial expense was to try to great a sterile environment, tried to exclude animals, remove all the while of habitat around

the field, terribly destructive, frankly. but now over time in leafy greens we've learned and i think the state and federal authorities have been involved in this process have all learned, really have to determine the risk. so, for example, if there are deer prints in your field and it looks like do you have eaten your cabbage, let's stick with the cabbage analogy, maybe, and the rule now states let's cordoned off that section of your field, you just that section of the field, as a rather than setting 30-foot fences around every field in america with netting to prevent birds, let's have a safety program in place that identifies animal intrusion. when you identify you cordoned that ofcom you cordoned that section off rather than what was the old practice which was i had to exclude everything, if a single to cut in fuel, you just the entire field to not just the section that the animals in but you just the entire field. so i think we are hopeful that fda recognizes that.

thank you. >> next -- wrong one. thank you, dennis. our wrapup presented this morning is paul muller of fully belly farms, a certified organic farm near sacramento, california. poll? >> thank you, charlie. thank you to the farm foundation for having me here. certainly see the issues running food safety as complex. of the food safety organ of food system that sources food from all over the world where there's issues to be dealt with there. we have complex agricultural system in this country with small farms and large farms, and each one occupying a different space in the market system. it's a complex issue where we

fit into all skills and capacities of farms to go ahead and deal with the fsma rules that are being handed down and impose on agriculture. it's tending to say that one kind of regulation will fail. i think that may not work in the real world. the rule creates a assurance of action which i think you do need to bury preventative in, and looking at how we approach food safety but there are worlds apart with us walk around washington, d.c., i came from a from yesterday of walking around, it's a different world, a different reality. it's totally incredible space between understanding of what goes on in a biologically-based agricultural system and the bagel that i had this morning, and i had a lettuce and tomato on them that was to live ethically in a complex chain of relationships that moved up from california to here. and i could consume it with relative confidence is going to be good but i think that we need

to think about how we as urban consumers expect our food to be safe. we also expect it to be cheap. i think that's a conflict that is inherent in the system where we are looking at a system where cheaper food is mandated summit in the system and keeps on pressing agriculture i think integrator greater levels of concentration. far fewer people producing our food in the fields. there's fewer eyes per acre out there. people actually responsible for the product and out of that field. today with less than 1% of the u.s. population that farms. we pay 9% of our disposable income for food. far less than any industrialized nation. i think on the whole, agriculture has been safety within a pretty good job. there are tragedies that shake all of agriculture to its roots. as far as i talk to have incredibly been affected by the

virulence of some of the microbes and how those can pass through a system. and it becomes an indictment of the whole system, becomes the indictment of reform. i think that's part of the tragedy that is taking place right now. i wanted to bring to this form of a small farms perspective. our farm is like a lot of other farms. it started about 30 years ago. i grew up on a dairy farm in san jose, california. we have a farm about 350 acres now. our farm has been focused on growing about 70 different crops on those acres and we're focused on the health of us will come on stewardship, of natural resources, fostering more life and health in this welcome growing farm pollinators in a diverse system where we are trying to create a form that is ecologically sound and impact. we are looking to create market access as passionate as a beginning farmer. we started with borrowing $10,000 trying to figure out we buy a tractor. that some of the skill you're looking at.

we -- where to go in able to get into the farming business? a lot of young, small farmers are asking the same questions. we were interested in country at we deal with pesticides and food. fair return for our workers. the health and vitality of a form that can be generated several communities once again thrive but the issue of food safety needs to be put into this larger context of this larger matrix of issues around agriculture and rural communities. that is not sustained or in its focus, that it will, in fact, destroyed a lot of the people that i think are producing high according fruits and vegetables in this country through excessive amounts of paperwork, regulation, oversight, et cetera. we focus on marketing locally. about 95% of our commodity or product that we produce is sold within 150 miles of farm. we're focused on relationship driven marketing. most of our customers will notice for 30 years, we still

include customers whose children have been raised on our food. in those 30 years of selling produce locally we've never had a food incident, any kind of incident that we know. we sorting don't know everything that happens in someone's kitchen but we feel fairly confident the food we're selling is healthy, wholesome and vibrant food. we have 30 years of direct conversation with many of the customers about the quality and safety of the products in our field. i think our science-based approach to food safety is that we have intimate trade stability with the customers we serve. i think we represent many of what are called these food systems, new urban edge phones, small firms run the country that are beginning to crop up. we've never seen on our farm so many people applying for internships with us, so many young farmers interested in beginning in agriculture. a lot of them are not from a farm family to a lot of them are looking at this issue and wanted to find someplace where they can make a positive change and the

larger issues about food, obesity, diabetes, the fact that half of our population has a health related right issue, or diet related issue, i should put it that way. looking at these larger issues in trying to figure out what kind of farms to we really want. this is not intended to be a criticism a large-scale agriculture. this is intended to be a focused discussion on this month and how fsma will, in fact, create burdens to entry, create burdens to compliance, create burdens to moving up for farms that are in the middle and needed to supply local and regional markets. i didn't have a slide presentation because i'm not that slick, and i don't, not criticizing you guys. i didn't actually realize what i want to say into last night. my wife and i love said don't give them hell.

i molded over and about midnight after couldn't sleep because i was nervous about talking to all you guys. i had, i came up with an idea thaand that even though it may e too late to deflect fsma's implementation in the produce rule, hoping we can affect the produce rule in these ways. i think i want to say that fda, some of this is the wrong way. we're going the wrong way with his rule ever going to wrongly because of the impact on small and mid size from come on the risk activities. we are going in the wrong way because we know that we need the people eat more fresh fruits and vegetables, and we don't want them to be frightened of the food safety issues associated with those. we want them to be knowledgeable to whether produced and how they produced and the care that is taken in going to get we want money to circuit locally. we know that in sacramento area, for example, close to where we

live, $8 billion in trade and food in that region that could be sourced locally. or a percentage of that could be sourced locally. you can begin to create jobs and economic movement around agriculture that can exist in places like sacramento and cleveland and boston. food systems thinking is becoming to become part of the discussion that we create a safer food system. i think we're going the wrong way because i think farmers are being put into a box and there are being put into the box where -- i could use more, if i could. being put into a box where there can be chilling to the idea of stability. they are beginning to say that, that we can control risk and create a more sterile and vibrant after in the fields that will, in fact, make food safety. we can control all the points of potential contamination in our fields in these widely dynamic biological systems.

and individually that point i think you will get themselves in trouble because once you in that box you can't get out of it. initially i think farmers were so taken aback by this is that doing everything they can to seek to comply with any point of contamination. i have farmers who talk to me, talked last week visited the coyotes are driving us crazy, there's no water. they're coming in and shooting up our orchards. in california's drought, in california's drought there is no green space for wildlife to go in a few. kind of space around on the field rededicating and growing are covered crops and other things. we are involved in this dynamic system, not approach are saying that turkeys are coming in and out of and how to keep them out. to what i going to do? are going to destroy the wildlife after i going to fans

it and turkeys are to because they will go over a 10-foot fence. are you going to begin to say it made we need to rethink this little bit my point here today is to say that i think we've gone the wrong way in understanding biological systems. i'd like to point out that each one of you has 100 trillion bacteria right now working in each of their bodies, 100. 10 times more than the cells you have in your body. you may have taken a shower this morning and you might have not that that a little bit but for the most part they are there in every one of us. we don't understand our fundamental relationship with the microbial world. we don't understand but we don't understand how we begin to create healthier outcomes by understanding our relationship with the microbial world. we are shooting from the hip in these standards by creating mechanisms, which again, prevention is important. as a small farm we have a gap

program. we're looking a point on our farm where we may have problems that could arise in our whole chain of relationship between ourselves and the consumer. but, in fact, we don't understand, and we don't argue for, the fact that we live in a biological funk. that the food, and in your very got, the food that you consume inoculates your very got with the beneficial, hopefully beneficial microorganisms. that creates everything that you need to become your own ecosystem. robert dunn of the universe of north carolina, a biologist calls it wildlife in our bodies. stanford michael biologist justin sonnenberg talks about the kennedys of bacteria in your system. how your indian system is really a microbial interaction system. we are just beginning to understand the science, and this is where we want science-based rule but we are excluding the

whole area of trying to understand the science of complex microbiology and how that affects the very healthy plant, also held as part of this dynamic of how you grow healthier foods, out each one of us is impacted, has a distinct relationship without food, how your dog can be of greater source of inoculation for you than most anything else, it links you and your family becomes a biological community because you are sharing microbes. it's a fantastic, elegant, complex world that we're just beginning to understand. we are just beginning to look at. you take the fda rule, and i think the way farmers look at it, is that i can't monitor all of us. i can't do what is required of me to monitor my fencing every day, go and check for any potential source of contamination, this king of you wanted your walks across the because he may have a suspected fecal contamination. i think we need to begin to

think about, isn't really a source of contamination. r. r. which is jumping to conclusion. and with all due respect to consumers that are out there that had kind of tragic incidents of foodborne illnesses, i think we have to look deeper. we have to look deeper at this whole level of soil, human, plant interaction, and how we began to shoot for a healthier outcome. i wish that we would have called this food safety modernization act, food safety more better health outcomes act. because it's not an absolute. i think, i think that farmers gave up a lot just in calling this a modernization act, because if it seems that the way it is presented to us, we had seven years of stagnation in agriculture, and farmers haven't changed over the last seven years, and thank god we've done something. it's important we do something and it's critical that we begin

to think about prevention. but it's critical we begin to think more broadly about the ecological framework, that the prevention is placed into, and we think more broadly about how we are a part of a complex microbiology coal system, that if you deny your existence committee tried to great star really, if you claim that some consequences that are profoundly off target, a third of people going to hospitals these they would have some form where they have diarrhea, that somehow created by the environment, overuse of antibiotics. they are doing fecal transplants into gut is that the vector load that they need in order to be healthy. is a crazy idea. it's what's happening. ..

all right. i'm going to stop there and give one notion that in looking at this in a broader sense we need to solve for pattern. gregory basin talked about solving for